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Montana 1115 Waiver Application Summary

September 17, 2019

McDermott+Consulting

On August 30, 2019, Montana submitted a new 1115 waiver application to the Centers for Medicare and Medicaid Services (CMS).  The waiver includes a work requirement and premium increases based on coverage duration.  The waiver is pending CMS approval and CMS is accepting comments on the application from September 12th, 2019 through October 12th, 2019.

Below please find our summary of key points of the waiver.

Work Requirements

Through the 1115 Waiver, Montana is proposing to implement Medicaid work requirements for certain Medicaid beneficiaries.  The following beneficiaries will be excluded from the work requirements: individuals who are medically frail, individuals with disabilities, pregnant women, individuals experiencing a severe acute medical condition, individuals who are physically or mentally unable to work, primary care providers for individuals who are unable to provide self-care, foster parents, full time students, individuals compliant or exempt from SNAP and TANF work requirements individuals in the criminal justice system, individuals who are chronically homeless, domestic violence victims, individuals living in a designated high-poverty area, individuals whose income exceeds an amount equal to the average of 80 hours per month multiplied by the minimum wage, and individuals exempt under federal law.

Individuals who do not meet an exempt category and who are enrolled in Montana Medicaid will be required to meet the work requirement.  Work requirement compliant activities include: employment, work readiness and workforce training activities, secondary and vocational education, substance abuse education and treatment, community engagement activities, community service and any other activity required by CMS for the purpose of obtaining necessary waivers.  Enrollees will be required to participate in 80 hours of work/community engagement activities each month to remain eligible for Medicaid benefits.

The Montana Department of Health and Human Services (DPHHS) will notify a program enrollee who is not in compliance with the work requirement that the enrollee has 180 days (or 6 months) to come into compliance, and failure to comply within the 180 day period will result in suspension from the program.  An enrollee who is suspended from the program for noncompliance may be reinstated 180 days after the date of suspension or upon determination by DPHHS that the program enrollee has been in compliance with the requirement for 30 days.

Premiums

Through the waiver, Montana is seeking approval to require demonstration enrollees to pay monthly premiums that increase based on the length of time they are enrolled in the demonstration program.  Specifically, enrollees will be required to pay monthly premiums equal to two percent of an enrollees household income for the first two years of participation.  Per state legislation, the premium will increase 0.5 percent in each subsequent year of demonstration coverage, up to a maximum of four percent of an enrollees household income.

Program enrollees who are exempt from the work requirement are also exempt from premium increases.  However, there are also additional exemptions for the premium requirements.

Within 30 days of an enrollees failure to make a require premium payment, DPHHS shall notify the enrollee that the payment is overdue and must be paid within 90 days from when the notice was sent.

If an enrollee with an income of 100 percent FPL or less fails to make payment for an overdue premiums, DPHHS will notify the Department of Revenue of the enrollee’s failure to pay.  The Department of Revenue will collect the amount due for nonpayment by assessing the amount against the enrollees annual income tax.  The enrollee will not be suspended from the program.  If an enrollee with an income over 100 percent FPL fails to make an overdue payment, DPHHS will follow the same collection procedures as for enrollees with an income less than 100 percent FPL, but will also suspend the enrollee from coverage.

DHHS will unsuspended an enrollee from coverage upon payment of the total amount of overdue premium payments or meeting a Medicaid eligibility group not subject to the demonstration.

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